Auditors filing suspicion reports usually know nothing about the client's accounts or transactions — so none of those data points may be mandatory for them
WPK. That is the core of the Wirtschaftsprüferkammer (WPK) response of 7 September 2026WPK to the Anti-Money Laundering Authority (AMLA) consultation on the draft implementing technical standard (ITS) under Article 69(3) of Regulation (EU) 2024/1624 (AMLR)WPK, which fixes the format for suspicion reports and the provision of transaction recordsWPK. The consultation runs until 20 September 2026WPK, and the WPK announced its response in a news item of 16 September 2026.
The ITS sets the format and the data points to be transmitted. The WPK's central objection is that too many data points are marked mandatory or technically requiredWPK, as already in the goAML system, making meaningful reports extremely hard for non-financial-sector obliged entities whose selective engagement gives them no full view of the concealed facts. That applies in particular to catalogue I.6 for auditors. All data points on accounts and on transactions must therefore be optional for WirtschaftsprüferWPK: in the non-financial sector, and at any rate for auditors, transactions normally play no role because auditors regularly execute no transactions for their clients. Where such points were mandatory, suspicion reports might be technically untransmittable to the Financial Intelligence Unit.
The response then works through the individual data points for the Annex 1 group of auditors, external accountants, tax advisers, lawyers and trust and company service providers. The register number query (DP0003) is superfluous, the chamber arguesWPK, because auditors must register with goAML and the number is known. The suspicion-assessment field (DP0017) and the start date of analysed transactions (DP0019) must be facultative rather than technically requiredWPK, since often no such assessment can be made or no start date is known — frequently only the suspicion of an unlawful act exists. Knowledge by other actors (DP0401) must be mandatory only where availableWPK, since whether others know is not necessarily known; the account field (DP0501) must be mandatory only where available or better optionalWPK, since client matters reaching auditors need not involve any account; and the transaction fields (DP0601, DP0605, DP0607–DP0609, DP0616, DP0617) must all be optional rather than mandatoryWPK for the same reason.
On costs, the WPK rates the one-off investment as disruptive in justificationWPK but sees no change to the reporting procedure itselfWPK: the impact assessment excludes technical implementation, goAML is prescribed in Germany for filing suspicion reportsWPK, and that should not changeWPK — it is in the interest of the member states and the FIUs that reports are filed at all, and no costs may arise for auditorsWPK. Recurrent costs it accepts only where changes are folded into goAML with the FIUs bearing the costWPK. Country-specific data points it rates as posing challengesWPK, noting cross-border incongruities, though those should affect very few cases.
Legal basis: draft ITS under Article 69(3) Regulation (EU) 2024/1624 (AMLR)WPK; WPK Stellungnahme of 7 September 2026 in the AMLA consultation closing 20 September 2026, announced 16 September 2026.
Review the AMLA ITS consultation on suspicion-report formats before 20 September 2026 and align reporting processes on account and transaction fields staying optional for auditors — report to the WPK any case where a mandatory field would block filing.
